When determining whether to file Suspicious Activity Reports (SARs), USBI incorrectly used a $25,000 monetary threshold applicable to banks rather than the $5,000 threshold applicable to broker-dealers and, as a result, did not timely file 42 SARs between April 2020 and August 2023. USBI failed to establish and implement policies and procedures reasonably designed to detect and cause the reporting of suspicious transactions in violation of FINRA Rules 3310(a) and 2010. The firm is censured and fined $500,000.